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    Can I as a government contract purchase parts for inventory as common parts, that is to say, parts we use on both commercial and government programs from hardware to manufactured subassemblies, with or without a government contract (at risk for award). My management would like to do this but I believe that I need to have accountability to the Contract for the CPSR reporting as well as for the Small Business reporting. I do not know how I can do this correcting if i do not buy for the contract and issue what I purchased for the contract to the contract.


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    Answer:
    It is not clear who the audit entity is in this case or the circumstances of the audit. In any event, you should contact the auditor and associated contracting officer (if this was a Government audit) for clarification as to the audit issue and how to resolve it.
     
    I assume you are NOT referring to purchasing items under FAR Part 51, Use of Government Sources by Contractors. If you are, you should already have FAR 52.251-1, Government Supply Sources, in the contract that authorizes you to use Government supply sources. FAR Part 51 sets forth the conditions and procedures under which the contracting officer may authorize, and the contractor may use, Government supply sources. You may also have more specific instructions and limitations in the authorizing contract.
     
    If you are referring to placing a purchase order (PO) as a private entity, not using Government sources, and you want to issue one purchase order to be able obtain a quantity discount, but need to be able to trace the parts to the PO for specific contract reimbursement, I see no reason why you could not use one purchase order to order as many items as you need, including items for common inventory (not traceable to a specific contract). If you are required to trace the cost of a specific item to a contract in a manner that identifies that contract, but you want to buy for other contracts and common inventory under the same order, it appears you could simply break the items out into separate lines with each line representing the funding source (prime contract number or common inventory). However, if the prime contract is a rated order, you must follow 15 CFR 700.12.  While all of this regulation is applicable in your case, you may want to particularly note the instructions at §700.17 (b): "A person may use a rated order to replace inventoried items (including finished items) if such items were used to fill rated orders, as follows:" It then gives very specific guidance for this situation, which appears to apply in your case, including the need to note the DPAS rating on the order.
     

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